This privacy policy explains how Tsomokos Group International (TGI), with its registered office at A Cetinjska 22/III/36, Beograd, Serbia, (“TGI”, “we”, “us” and “our”) processes personal data. We strive for transparency and trust when it comes to protecting your privacy, and aim to clearly explain how we collect and process your information. It is of utmost importance to us that you should enjoy using our products, services and website(s) without compromising your privacy in any way. We only collect, use, and process your personal information in accordance with actual data protection legislation. This includes but is not limited to Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) and applicable national data protection legislation. Your personal data is usually obtained directly from you, in which case, you provide your personal data on a voluntary basis. Specific cases of non-disclosure of personal data may affect the ability of TGI to properly provide services, and/or perform contractual obligations. Tsomokos Group International (TGI) acts on behalf of its subscribers and other clients in the capacity of a data controller.

FOR WHAT PURPOSES IS PERSONAL DATA PROCESSED?

TSOMOKOS processes your personal data as needed for the following purposes: (i) Provision of services – this includes the delivery of digital content (legal basis: processing necessary for contractual performance or for the implementation of measures taken before a contract is concluded) (ii) Processing payments – this includes the maintenance of payments, together with payment processors (legal basis: processing necessary for contractual performance) (iii) Marketing activities – this includes the delivery of personalized content, targeting of advertising or the sending of newsletters (legal basis: legitimate interest) (iv) Determination and enforcement of TGI legal claims (legal basis: legitimate interest) (v) Compliance with legislation If necessary, TGI will ask you for permission to process your personal data.

WHAT CATEGORIES OF PERSONAL DATA DO WE PROCESS?

Using the services provided by TGI, we may require the following data:

• Name, surname, job title, company and industry
• Address, telephone number, and email
• Payment details (payment card information)
• Your preferences and opinions on products and services
• Your browsing activity on our websites

WHEN DO WE COLLECT DATA?

All data that we receive is obtained directly or indirectly from you when you choose to use our services. This includes the following situations:

• When you subscribe to our newsletter
• When you pay for or use our services
• When you register to our events
• When you browse our website
• When you share content from our website, or
• When you interact with us via social media platforms

WHO DO WE SHARE PERSONAL DATA WITH?

In order to provide you with the services you request, your personal data may be provided to the following third parties: (i) Selected employees of TGI (ii) Service providers – those ensuring provision of the services provided by TGI, in particular software services providers, marketing providers, customer service providers, and distributors of marketing and other materials such as newsletters, including employees of such entities (iii) Tax advisors, professional advisers (e.g. auditors, lawyers), including employees of such entities (iv) Entities providing payment services (v) Social media providers – using the services of TGI together with a social network may require TGI   to share your personal data with social media providers

ΙNFORMATION WE DO NOT TRACK

We do not track or collect any sensitive information about you. This includes race, religion, ethnicity, and political opinion.

HOW LONG IS YOUR DATA RETAINED?

We keep your data for the period of time necessary to fulfill the purposes of processing as defined above. This data, however, will be erased once you stop interacting with TGI (i.e. after delivery of a particular service), unless TGI has a legitimate interest in keeping the personal data longer (i.e. to protect TGI’s legal claims). This would be the case if TGI  had a legal obligation to keep your data for a longer period of time (for example, based on applicable accounting rules), or in cases where applicable law obliges us to keep such records for a longer period.

IS YOUR PERSONAL DATA SECURED?

We store electronic, and in some cases physical copies, of your personal data. In accordance with best practices, we maintain security safeguards that protect your data. We strictly limit who is allowed to access the information and keep this number to a minimum. In addition, we maintain physical and cyber safeguards, server protection devices, and software to minimize possible loss, misuse, or alteration of your data. Your personal data may be stored and processed in countries where TGI carries out business or where its service providers are located. These countries may apply different privacy rules than the European Union, or the European Economic Area (EEA). TGI has put in place appropriate contractual and other measures to protect your personal data when personal data is transferred to related parties and/or third parties located in other countries. In the case of cross-border transmission of data from the EEA to countries where the European Commission recognizes an insufficient level of protection of personal data, the controller ensures that those data recipients are bound by EU standard contractual clauses to protect your personal data.

WHAT ARE YOUR RIGHTS?

Regarding your data, you have the following rights: (i) To request access in order to correct or delete your personal data, as well as to restrict its processing; however, your right to delete or restrict processing is applicable only if TGI is not required to process it on another legal basis (i.e. compliance with a legal obligation) (ii) To object to the processing of your personal data processed with a legitimate interest, as well as against processing for marketing purposes If you wish to exercise your rights above or have any questions regarding the processing of your personal data, please contact the administrator by email at: info@tsomokos.gr. The information that TGI is required to provide to you regarding the processing of your personal data may change over time and/or become outdated. For this reason, TGI reserves the right to modify and change these conditions at any time. These changes will be reflected in this statement, and therefore, should be checked regularly for any updates and/or amendments of this policy.

TGI & COOKIE USE

When you visit our website, we may store information on your computer in the form of cookies. A “cookie” is a small piece of data stored on the user's computer by the web browser while browsing a website. The browser then presents this information to the web server, allowing for us to automatically identify you the next time you wish to visit our site. Please be informed that the cookies only save the Internet protocol address and do not contain any of your personal details. Cookies are used to custom-tailor, and therefore improve your user experience. If you do not want wish for the use of cookies, you can also decline by changing the settings in your browser to "refuse cookies". It should be noted, however, that by refusing the use of cookies, the experience may not be as user friendly and restrictions may be applied to various areas of our site.

CHILDREN & PERSONAL DATA

TSOMOKOS does not knowingly seek or collect personal data from children below the age of 18. If we detect that a child has provided us with personal information of any sort, we will proceed with discarding that child’s personal data from our records as soon as possible.

OUR DETAILS

TGI is the data controller for personal data we collect through the means stated in this Privacy Policy. Our full contact details may be found below.

Tsomokos Group International (TGI)

A Cetinjska 22/III/36, Beograd

Tel: +381 11 303 2235
office@tsomokos.rs